Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Undisclosed foreign investments in Dubai and Singapore were held unsubstantiated because the assessee failed to produce confirmations or reliable proof of the named lenders and source of funds; therefore the CIT(A)'s acceptance of disclosure was reversed. The tribunal reasoned that book entries alone did not establish the nature or origin of the investments and directed the assessing officer to require confirmations from the two foreign entities and satisfy himself on source and nature of funds. The tribunal also held that compounding of foreign exchange offences does not relieve the assessee from incometax or Black Money Act consequences, and remanded the matter for fresh inquiry.
Undisclosed foreign investments in Dubai and Singapore were held unsubstantiated because the assessee failed to produce confirmations or reliable proof of the named lenders and source of funds; therefore the CIT(A)'s acceptance of disclosure was reversed. The tribunal reasoned that book entries alone did not establish the nature or origin of the investments and directed the assessing officer to require confirmations from the two foreign entities and satisfy himself on source and nature of funds. The tribunal also held that compounding of foreign exchange offences does not relieve the assessee from incometax or Black Money Act consequences, and remanded the matter for fresh inquiry.
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